Shamrock Capital Advisors
Types of Information We Collect
- Contact details, such as your full name, e-mail address, postal address and telephone number;
- Educational, nationality and professional background information;
Usernames and passwords;
- Payment information;
- Comments, feedback, posts and other content submitted to staff; and
Interests and communication preferences including marketing permissions where appropriate.
The types of PII we collect and use are generally limited to the categories listed below, but may include other information when needed to provide a Service:
- Contact Details – Name, address, email, phone number, Service requested
- Investment Documentation – Financial information, fund details
Restricted Use Regarding Minors
This Site is not intended or designed to be used by children under the age of 13. We do not collect PII from any person we know to be under the age of 13 and instruct children under 13 not to send us any information.
Purposes for Collecting Your PI
You may provide your PII to Shamrock in order to fulfill a Service. You are then entering a business relationship with Shamrock and are agreeing to the use of that data by Shamrock and its applicable worldwide affiliated companies, as stated in this Privacy Notice. We request PII for a variety of purposes throughout your interaction with Shamrock, some of which are listed below:
- Contacting you or your designated representative by phone, email, fax, or mail;
- Providing you or your representative with marketing communications;
- Creating and managing your account with us;
Sharing information about our Services including investment research;
- Facilitating financial transactions related to your account;
Fulfilling our legal and regulatory obligations;
- The performance of obligations under any applicable agreements;
The administrative processes (and related communication) carried out between Shamrock in preparing its services;
- Ongoing communication with you and/or your designated contacts;
The ongoing administrative, reporting and other processes and communication required to operate the business in accordance with the agreements and other applicable documentation between the parties;
- Any legal or regulatory requirement; or
- Any other purpose that has been notified, or has been agreed, in writing.
We use various technologies to collect other types of information, including PII, automatically. For example, in order to measure the usefulness and efficiency of our Sites, we automatically track certain information from all visitors to our Sites. The types of information we might track may include the Internet address that you just came from, which Internet address you go to, what browser you are using, your IP address, your internet service provider, date and timestamp information, or clickstream information.
We also use analytics providers, such as Google Analytics to help us evaluate the Sites. To opt out of the aggregation and analysis of data collected about you on the Sites by Google Analytics, visit https://tools.google.com/gaoptout and download and install the Google Analytics Opt-out Browser Add-on.
Sharing Your PII
Your PII may be combined with information we receive from other sources, or it may be provided to other organizations we work with. This section details that sharing of your PI.
1. Receiving PII from Third Parties
We may receive information about you from other sources and combine that information with the PII we collect directly from you. For example, we may receive payment information from the organization you use to pay us in order to correct our records. Additionally, to promote protection of your identity, we also may collect credit or identity information which we use to help prevent and detect fraud.
2. Sharing PII with Third Parties
We will not sell your PI. If we share your PII with third parties performing services for us, or acting on our behalf, we will not allow them to use your information for other purposes, and we will contractually require them to protect your information.
We may share your PII with our affiliates, business partners, and other third parties. We may do so for the purposes of operating our business, delivering and improving the Services we provide to you, as well as for other legitimate purposes permitted by applicable law such as sending marketing and other communications related to our business.
We may share your PII with third parties for a variety of additional purposes including, but not limited to:
- Within Shamrock and our affiliates and subsidiaries for data processing or storage purposes;
- With business partners and suppliers to provide Services and help facilitate transactions (including processing orders, event registrations, data storage, marketing communications and customer support); or
- In response to a request from law enforcement, government authorities, or other third parties as necessary to comply with legal process or to meet national security requirements.
Protection of Personally Identifiable Information
We maintain physical, electronic, and procedural security measures that comply with applicable legal and regulatory standards to safeguard your PII. Access to such information is restricted to those employees who are trained in the proper handling of client information and have a legitimate business need to access that information. We follow generally accepted standards to protect the PII you submit to us, whether that information is in transit or at rest. No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security.
Your EU Data Subject Rights
The European Union’s General Data Protection Regulation (“GDPR”) is a sweeping piece of legislation that grants EU residents increased control over their personal information. The GDPR allows consumers to access their personal information and find out details of how that data is processed, to rectify inaccurate personal information, to have their data erased (when certain conditions are met), to restrict processing of their data, and more. It requires affected companies to create processes to comply with and facilitate consumer data requests, to update their privacy policies, and to ensure that personal information is secured.
Specifically, the GDPR and other national privacy laws provide data subjects with certain rights regarding their PII. If you are an individual who resides in the EU and whose PII is collected and processed by Shamrock, you have the right to:
- Request access to your data
- Rectify your data
- Take your data (in a readable, “portable” format) to another service provider
- Erase your PII
- Restrict or object to the processing of your PII
- Lodge a complaint with a Member State Supervisory Authority
Withdraw previously given consent to collect and process PII (which will not impact PII processed before the withdrawal)
PII Rights for California Residents
The California Consumer Privacy Act (“CCPA”) provides some California residents with certain data rights regarding what we do with your PI. If you are a California resident and it is determined that the CCPA applies to you, this section details those rights, how you may exercise them, and what Shamrock will do in response.\
California residents have the right to request that we disclose, free of charge, the categories and specifics of the PII we collect about California residents (and/or, if applicable, sell or otherwise disclose to a third party for business purposes). We require a verifiable request from the California resident to ensure that it is, in fact, the California resident who is requesting such a PII disclosure. Once we verify the request, we will provide that information.
A request for disclosure can apply to any such PII mentioned in the previous paragraph for as much as twelve months preceding your request. Be advised that we are not required to disclose such information about the PII we collect more than twice in a twelve-month period.
Following our verification of your request, we will disclose, unless otherwise restricted by law or regulation, the following PII we collect:
- The categories of PII we have collected
- The categories of sources from which the PII is collected
- The business or commercial purpose for collecting or selling that PI
- The categories of third parties with whom we share PI
- The specific pieces of PII we have collected
Following our verification of the request, we will disclose, unless otherwise restricted by law or regulation, the following PII that we sell to a third party or otherwise disclose for business purposes:
- The categories of PII we have collected that we sell or disclose
- The categories of sources from which that PII is collected
- The business or commercial purpose for collecting, selling, and/or disclosing that PI
4. Opting Out.
Under the CCPA, we may sell the PII we possess unless we are advised not to. This is often referred to as the right to “opt-out.” Currently, however, Shamrock does not sell PI.
5. Sale of Minors’ PII Only with Opt-In Consent.
Under the CCPA, we may only sell the PII we possess about a consumer who we believe to be between the ages of 13 and 16 if the consumer consents (“opts-in”). If we believe our consumer to be less than 13, we may only sell the PII we possess about that consumer if the consumer’s parent or guardian consents (“opts-in”). Currently, however, Shamrock does not sell the PII of minors.
6. Deletion of PI.
California residents have the right to request that we delete the PII we have collected. Following our verification of the request, we will comply with the request and delete any or all the PII in our possession that we collected from the California resident and/or any or all such PII in the possession of our service providers, unless otherwise restricted by law or regulation.
7. Non-Discrimination for Exercising Your PII Right.
We follow the requirements of California Civil Code §1798.125, and will not discriminate against any consumer who exercises the rights under the CCPA.
Contacting Us to Exercise Your Privacy Rights